European Accessibility Act 2025: What Employers Must Know

Introduction

The European Accessibility Act (EAA), formally Directive (EU) 2019/882, sets common EU accessibility requirements for a defined set of products and services. EU member states had to transpose it into national law by 28 June 2022 and apply those rules from 28 June 2025. It is a product and service regulation aimed at consumers — which means its relevance to employers is real but narrower than is often claimed. This guide explains what the EAA actually covers, where it touches employers, and which other EU rules govern accessibility in recruitment and at work.

What Is the EAA?

The EAA establishes common accessibility requirements for products and services placed on the EU market. Unlike the Employment Equality Directive (2000/78/EC), which addresses discrimination in employment, the EAA targets the accessibility of products and services themselves.

Products Covered (placed on the market after 28 June 2025)

• Consumer general purpose computer hardware and their operating systems
• Payment terminals and self-service terminals such as ATMs, ticketing machines, check-in machines and interactive information terminals
• Consumer terminal equipment used for electronic communications services (such as smartphones) or for accessing audiovisual media services (such as TV equipment)
• E-readers

Services Covered (provided to consumers after 28 June 2025)

• Electronic communications services
• Services providing access to audiovisual media services
• Elements of air, bus, rail and waterborne passenger transport services — websites, mobile apps, electronic ticketing, travel information and interactive terminals (for urban, suburban and regional transport, only interactive self-service terminals)
• Consumer banking services
• E-books and dedicated software
• E-commerce services
• Answering emergency communications to the European emergency number 112

Microenterprises — businesses with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million — that provide services are exempt from the service accessibility requirements.

Does the EAA Apply to Recruitment and HR Systems?

Mostly not directly. The EAA's services are services "provided to consumers", and the directive defines a consumer as a person acting outside their trade, business, craft or profession. E-commerce services are defined as services provided at a consumer's request "with a view to concluding a consumer contract". A job application or an internal HR tool is not a consumer contract, so careers pages, applicant tracking systems, intranets and HR self-service portals are generally not in the EAA's scope simply because they are digital.

Employers should still care, for three reasons:

1. Your Organisation May Be an EAA Service Provider

If your organisation sells to consumers online, provides consumer banking, telecoms, audiovisual access, e-books or passenger transport, the EAA applies to those customer-facing services. Your digital teams will need to meet its requirements, and accessibility skills become part of the job for developers, designers and content staff.

2. Recruitment Accessibility Is Required by Employment Law

The Employment Equality Directive (2000/78/EC) covers "conditions for access to employment … including selection criteria and recruitment conditions". Its Article 5 requires employers to provide reasonable accommodation so that a person with a disability can access, participate in or advance in employment, unless this would impose a disproportionate burden. An inaccessible application process can therefore create discrimination risk under national employment law, even where the EAA does not apply.

3. Public Procurement

For products and services within the EAA's scope, the directive's accessibility requirements count as mandatory accessibility requirements under the EU public procurement directives (2014/24/EU and 2014/25/EU). Suppliers to public bodies should expect them to be written into tenders.

Technical Standards: What "Accessible" Means

Under Article 15 of the EAA, products and services that conform to harmonised standards published in the Official Journal of the EU are presumed to meet its accessibility requirements. For digital services, the directive requires websites and mobile apps to be made accessible "by making them perceivable, operable, understandable and robust" — the same four principles that structure the Web Content Accessibility Guidelines (WCAG). France's consumer authority (DGCCRF) points businesses to the European standard EN 301 549 and to WCAG as practical references.

Key Requirements for Digital Platforms

Timeline and Transition

Member states may also allow self-service terminals already in use before 28 June 2025 to stay in service until the end of their economically useful life, but no longer than 20 years after entry into use.

What Applies From 28 June 2025

• New products placed on the market must comply
• Covered services provided to consumers must comply, and service providers must publish information explaining how their services meet the accessibility requirements
• Member states must have procedures to check compliance of services, follow up complaints and verify corrective action

National Implementation Examples

Germany (Barrierefreiheitsstärkungsgesetz — BFSG)

• Enacted on 16 July 2021 to transpose the EAA; applies to products placed on the market after 28 June 2025
• Market surveillance is carried out by authorities of the federal states (Länder)
• Fines: up to €100,000 for the most serious offences (such as placing a non-compliant product on the market) and up to €10,000 for other offences
• Service contracts concluded before 28 June 2025 may continue unchanged, but no longer than 27 June 2030; self-service terminals may stay in use for up to fifteen years after entry into use

France

• Implemented through the Consumer Code (Article L.412-13) and Decree 2023-931 of 9 October 2023
• The DGCCRF checks compliance and can order businesses to bring products and services into conformity, with possible penalty payments and publicity measures
• Breaches are fifth-class offences carrying fines of €7,500, cumulative according to the number of infringements found; persistent non-compliance can lead to suspension of products from the market

Penalties and Enforcement

The EAA requires penalties to be effective, proportionate and dissuasive, accompanied by effective remedial action, but leaves the specific amounts to member states (see the examples above). The directive also requires that:

• Consumers can take action before national courts or competent administrative bodies to enforce the rules
• Public bodies, associations and organisations with a legitimate interest can act on behalf or in support of a complainant, with their approval

Employer Action Plan

Check Your Scope

1. Map your customer-facing services: Identify any products or consumer services your organisation provides that fall under the EAA, and the national law that applies in each country where you operate
2. Check the microenterprise exemption: Service providers with fewer than 10 employees and no more than €2 million turnover or balance sheet total are exempt from the service requirements

Make Recruitment Accessible Anyway

1. Audit your careers site and ATS: Test against WCAG 2.2 Level AA — the EAA may not require it, but anti-discrimination law and good practice do
2. Review vendor contracts: Ask ATS, HRIS and LMS providers for accessibility conformance information
3. Offer alternatives: Ensure recruiters can provide alternative application methods and adjustments when digital barriers exist

Ongoing

1. Embed accessibility in procurement: Add accessibility requirements to RFPs for all HR technology
2. Provide a feedback channel: Make it easy for candidates and employees to report accessibility barriers
3. Test regularly: Combine automated and manual testing, including testing with assistive technology users
4. Document decisions: Keep records of audits, remediation and any disproportionate-burden assessments — the EAA requires economic operators to document such assessments and keep the results for five years

The Business Case Beyond Compliance

The European Commission estimates that 90 million people in the EU live with a disability — a large customer base and talent pool. Accessibility improvements such as clear navigation, readable text and keyboard access improve usability for everyone, and organisations that get accessibility right strengthen their employer brand.

Resources

• European Accessibility Act full text: EUR-Lex Directive (EU) 2019/882
• Employment Equality Directive 2000/78/EC: EUR-Lex
• WCAG overview: w3.org/WAI
• German BFSG: gesetze-im-internet.de
• France (DGCCRF guidance for businesses): economie.gouv.fr
• European Commission — European Accessibility Act: commission.europa.eu